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The landfill began operations in the 1950s in borrow pits that provided material for building a
road on the island. The operators dug additional trenches for waste disposal. In 1974, the
original pits and trenches were closed and some were covered with a 5-foot-thick clay soil layer.
In the late 1970s, an above-ground, bermed disposal cell was constructed atop the cap over the
original landfill. The U.S. Army Corps of Engineers used part of the site to dewater sediments
dredged from the river, and the dewatered sediments were used as cover for the landfill. This cell
was closed in 1984, and, in 1987, a 2-foot-thick clay cover was constructed over the landfill.

The clay cover over the second, above-ground phase of the landfill was not sealed to the clay
cover on the original landfill, and there have been reports of leachate seeping from the landfill into
surrounding ditches. Organic chemicals, including polychlorinated biphenyls (PCBs) have been
found in the soil and groundwater, especially on the west side of the landfill, where a layer of
organic chemicals has been found at the bottom of the groundwater. Surface soil on the landfill
contains elevated concentrations of metals, pesticides, polynuclear aromatic hydrocarbons
(PAHs), and other semi-volatile organic chemicals. There have also been reports that wastes
from the older phase of the landfill have been seen on the surface where the landfill was not
capped. Sediments in the Saginaw River near the site contain the same chemicals. Some fish
living in the Saginaw River contain high concentrations of PCBs, from the BCM site and many
other sources in the river's watershed. The Michigan Department of Community Health (MDCH)
maintains an advisory that no one eat any carp or catfish or large quantities of fish of any other
kind from the Saginaw River because of this contamination and contamination with dioxin, not
attributed to the BCM site.

There is no evidence that groundwater on the island is used for human consumption. All
residences on the island are connected to the Bay County public water supply, whose source is in
Saginaw Bay approximately 15 miles north of the site. The municipal system is regularly tested
for chemical contaminants, and there is no record of any contamination found in this monitoring.
One resident reported using well water only to water domestic animals. Groundwater at the site
flows primarily into the Saginaw River. There is a fence around three sides of the landfill, though
not along the river side. There are plans to install a fence along the river side of the site in the
summer of 1996.

The BCM site poses a public health hazard under current conditions. The surface soil on the site
contains organic chemicals and metals at concentrations potentially of human health concern,
access to the site is not completely restricted, and some trespass has occurred. PCB-contaminated groundwater from the site discharges to the Saginaw River. The concentrations of
PCBs in the water and sediments of the river do not pose a significant health threat from direct
human exposure. However, the PCB discharge contributes to PCB contamination in the fish of
the river through bioaccumulation of the chemicals in the food chain. Exposure to the soil on the
site is not likely to be sufficient to cause adverse health effects, however, consumption of fish
from the river might expose the consumer to sufficient PCBs to risk adverse health effects. The
assessment recommends that access to the site be further restricted to deter future exposure, that
environmental transport of contaminated material from the site during remedial activities be
minimized, that the groundwater be further investigated to determine whether potential exposure
pathways are complete, that leachate from the landfill on the site be controlled, that access to the
ditches on the site be restricted, and that remediation to prevent discharge of contaminated
groundwater to the river be implemented promptly. The MDCH will renew efforts to increase
public awareness of and compliance with the existing fish consumption advisories on the Saginaw River. Health education activities included in the Public Health Assessment process should include advice about the potential health hazards to children playing on the site or in the perimeter ditches at the site.

BACKGROUND

The Bay City Middlegrounds Landfill site was proposed for the United States Environmental
Protection Agency (U.S. EPA) National Priorities List (NPL) on February 16, 1995.

A. Site Description and History

The Bay City Middlegrounds (BCM) site is an abandoned landfill located on Middleground Island
in the Saginaw River in southwestern Bay City, Michigan. The site covers approximately 40 acres
on the west side of the island, between the west channel of the river and Evergreen Road, north of
Hotchkiss Street (Cass Avenue) (see Figure 1). Features of the site are shown in Figure 2.

In the early 1950s, the City excavated soil and gravel from the site to provide fill for the
construction of Evergreen Road. Beginning in 1956, the excavations on the site were used for
disposal of wastes. When the existing pits were filled, new trenches, 15-20 feet deep and
extending below the water table, were dug for further waste disposal. Though there are few
records of the specific wastes disposed of at the site during this period, available records and
interviews with landfill workers indicate that the wastes disposed of included wood, paper,
demolition material, garbage, and industrial wastes.

In the early 1970s, the trench and fill method of disposal was abandoned at the site, and by 1974,
a 5-foot-thick cap of clay and soil was placed over the southern part of the trench and fill areas
(1). Approximately one-third of the landfill was not capped (2). The City then constructed
berms on top of the cap and deposited more wastes between the berms. At the same time, the
City agreed to allow the U.S. Army Corps of Engineers (CoE) to deposit sediments from
dredging the Saginaw River on the north end of the site. A dewatering basin was constructed at
the north end of the site using berms and the dewatered sediments "were then used for other
purposes which included being used for daily cover at the landfill."(1) The landfill ceased
operation under orders from the State of Michigan in August 1984. In 1987, a 2-foot-thick clay
cap was constructed over the bermed landfill and a leachate collection system installed around the
bermed landfill (1). In late 1993 or early 1994, the site was fenced (4), on the north, east,
and south sides only. The west side of the site, along the river bank, is not fenced and the fence at
the north and south ends does not extend into the river. A group of Potentially Responsible
Parties (PRPs) for the site is planning to install a fence along the river side of the site in the
Summer of 1996 (5).

The entire Middleground Island was originally wetlands, whose surface was barely above the river level before the island was developed. The initial fill materials included wood chips from nearby
sawmills. There had been another landfill on the north end of the island for years before the
BCM-site landfill was used. Borings drilled in 1929 for the footings of the bridge across the north
end of the island found compacted trash. The Bay City Boys and Girls Club and Bay City Rowing
Club buildings on the north end of the island were built atop the old landfill (6).

The cap over the bermed landfill was not fully sealed to the lower cap, and leachate has seeped
out of the mound and flowed into the ditches along Evergreen Road and Hotchkiss Street (6).

Contractors for Bay City conducted two phases of a Remedial Investigation (RI) of the site in
1989 through 1991. Bay City's contractors found high concentrations of PCBs in soil and
groundwater, primarily in a relatively small area on the west side of the landfill. The highest
concentration of these chemicals were found in a layer of organic solvents at the bottom of the
shallow groundwater in that area.

Bay City's contractors identified five layers of subsurface materials (from the top down): 1-5 feet
of soil cover, 25-30 feet of sandy soil mixed with landfilled materials, 10-20 feet of sandy silty
clay, approximately 20 feet of sand with some interbedded clay on the west, and at least 5 feet of
clay. The second and fourth layers contain aquifers, apparently hydraulically separated from each
other by the clay between them though both aquifers are hydraulically connected to the Saginaw
River. The sandy silty clay layer has not been proven to be continuous across the site, and may
not effectively separate the aquifers (4). Contamination has only been found in the shallower
aquifer (1, 7). Bay City's contractors conducted a third phase of the RI in September and
October 1992 (8).

The Michigan Department of Natural Resources (MDNR) conducted an Expanded Site
Inspection (ESI) of the site in April 1992 (3). Surface soil samples ranged in depth from 3 to 6
inches. A pilot study of a low-temperature thermal desorption technology for treatment of PCB-contaminated soils was carried out from September to December 1992 using wastes from the site
(3, 9).

In May 1994, the Michigan Department of Public Health (MDPH)(2) prepared a Health
Consultation for the Bay City Middlegrounds site. The consultation concluded that the BCM site
posed a health hazard under current conditions, however, people were not likely to be sufficiently
exposed to contaminants of concern at the site to incur adverse health effects. Surface materials
on the site contain concentrations of contaminants at levels potentially of health concern on
frequent or long-term exposure, but trespassers are not likely to be on the site frequently or for
long periods of time. The consultation recommended improving the restriction of access to the
site and further investigation to determine if contaminants were migrating off the site (10).

B. Site Visits

On February 10, 1994, John Filpus of MDPH, MDNR personnel, and U.S. EPA personnel visited
the site. The site was heavily snow-covered, which prevented observation of the ground surface.
They did see the proximity of the homes on the south end of the site and the relative location of
the area of high PCB concentration in the groundwater. They also noted snowmobile tracks
across the site.

On June 10, 1994, Brendan Boyle of MDPH visited the site area. He observed the site from
outside the fence and the neighboring properties. He also talked with a resident of the island.

C. Demographics, Land Use, and Natural Resource Use

The nearest residences to the site are two houses and an unoccupied trailer located less than 200
feet from the site fence, across Hotchkiss Street to the south. There are 34 houses on the south
end of the island, including the two along Hotchkiss Street. Across Evergreen Road east of the
landfill are commercial properties, including a marina, boat storage, and a now-closed restaurant.
On September 8, 1995, the MDNR and the U.S. Army Corps of Engineers issued a wetlands
permit application for a marina renovation and boardwalk installation project on Middleground
Island across Evergreen Road from the landfill (4). The north end of the island includes
several ball fields, the Bay City Boys and Girls Club, and a rowing club. On the mainland, the east
shore of the Saginaw River near the island is well-developed, with a marina and other commercial
enterprises along the shore and residences further inland. The west shore of the river near the
island is undeveloped, except for the Prestolite factory (now owned by Allied Signal) across from
the north end of the landfill.

As of the 1990 U.S. Census, 7,635 people lived within 1 mile of the BCM site. A partial ethnic
and age breakdown of the population within 1 mile of the BCM site is given in Table 1. Approximately
half of Bay City (1990 total city population 38,730) is within 3 miles of the BCM site. As of the
1990 U.S. Census, the population of Bay County was primarily non-Hispanic white, with 1.1%
African-American, 0.7% Native American, 0.7% Asian or Pacific Islander, 1.4% other race.
Three per cent of the county population was Hispanic (11).

During Phase I of the RI in 1989, Bay City's contractors carried out a door-to-door survey on
Middleground Island, to locate any private wells on the island. All residents interviewed reported
that their homes were served by Bay County public water system. The Bay County public water
system uses water from Saginaw Bay on Lake Huron, approximately 15 miles north of the site.
The residents reported that there had never been wells for human consumption use on the island.
Attempts to drill wells had never succeeded in finding potable water. Until the municipal water
system was extended to the island in the 1960s (12), bottled water was brought onto the island
for drinking and cooking. River water was used for laundry, washing, lawn watering, and other
purposes. The occupants of one residence, north of the landfill, whose private well had been
tested by the MDPH the year before, said the well was only used for summer watering of
domestic animals. The owner of the restaurant east of the landfill said there was a well on his
property, but it was not currently used (1). As of this writing, the restaurant is closed. The
residence north of the landfill has since been vacated and demolished (4).

The Saginaw River flows to the north around Middleground Island. The west channel of the river
is adjacent to the BCM site, the east channel is approximately 1,000 feet east of the site. The
river empties into Saginaw Bay, part of Lake Huron, approximately 7 miles northeast of the site.
The river is used for recreation, including fishing and boating.

According to Michigan Department of Environmental Quality (MDEQ)(3) staff, small-game and
bird hunters hunt on the island during the appropriate seasons. Hunters have been seen near the
piles of dredged sediment from the Saginaw River within the fenced area of the site fence (2).

D. Health Outcome Data

Trespassers on the site have been exposed to chemical contaminants, but the exposure is not likely
to have been extensive enough to result in adverse health effects. A resident of Bay City has
expressed concern about the incidence of cancer in his community. The MDCH Division of
Health Risk Assessment has obtained cancer incidence data for the area from the MDCH Office of
the State Registrar and Division of Health Statistics.

COMMUNITY HEALTH CONCERNS

The MDNR/MDEQ has organized a Community Information Committee (CIC) for environmental
contamination concerns in the Saginaw River area. At regularly-scheduled meetings of the CIC,
people living on the island south of the site have asked whether it was safe to allow their children
to play in the ditch around the landfill (13).

On September 8, 1994, John Filpus of the MDPH attended a meeting of the CIC. The meeting
included presentations by the U.S. EPA about the status of the BCM site in the Agency's
Superfund Accelerated Cleanup Model (SACM) program and by a U.S. EPA contractor about a
demonstration project on the site. One citizen expressed concern that the chemicals from the site
might get into the city water supply. The city's water intake is in Saginaw Bay approximately 15
miles north of the BCM site, and at least potentially downstream of the site, depending on the
currents within the bay.

The MDPH released a draft of this Public Health Assessment for public comment on January 31,
1996. The initial public comment period lasted until March 1, 1996, and a second public
comment period was provided from March 14, 1996, to April 15, 1996. MDPH/MDCH received
comments on the draft assessment from a representative of the City of Bay City and from a
contractor for a group of the PRPs for the site. MDCH responses to these comments are given in
the Responsiveness Summary at the end of this document.

During the public comment periods, MDCH also solicited health-related concerns and questions
about the site from the public. Their concerns and questions included the following:

Soil and water contamination on surrounding property.

Are there any health hazards from living in the area of the landfill? I am concerned about
radioactive contaminants, airborne contaminants, and any substance that may be surfacing that are
harmful to health. Will traveling to and from my home on the Middlegrounds and passing the
dump site daily put me and my family at an increased health risk? If so, what risks? (A
consolidation of comments from several residents of the south end of Middleground Island.)

Does swimming and boating in the waters of the Saginaw River near the Middlegrounds
increase my (our) risk of health problems? If so, how?

Should we be buying bottled water? Could our drinking water be contaminated?

I wish that you would let people know that there are no proven PCB-related health risks
instead of scaring everyone unnecessarily.

(From a resident of Middleground Island): It is rumored that there is a high incidence of cancer
in families that have lived on Evergreen [Road, on Middleground Island] for a long time. (From a
Bay City resident, not living on Middleground Island): We here in Bay City have a very high
cancer rate. Four of my peers (age 50s) are presently struggling with cancer. Two others are
already deceased. Some doctors are now saying it's the environment.

Is there any documented health problems that have been reported that could be directly linked
to the Middlegrounds? Historic health impact and effects on Bay City residents during the 1950s
through current.

How will notification be made to the public regarding not eating the Great Lakes fish? I don't think it is well known.